Kallich v. Commissioner
United States Tax Court
R determined deficiencies and additions to tax for each of the taxable years 1981 and 1982 in respective amounts greater than $ 10,000. Ps seek to have their case conducted under the small tax case procedure by conceding a portion of the deficiency and additions to tax for each year.
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R determined deficiencies and additions to tax for each of the taxable years 1981 and 1982 in respective amounts greater than $ 10,000. Ps seek to have their case conducted under the small tax case procedure by conceding a portion of the deficiency and additions to tax for each year. Held, Ps are entitled to have their case heard under the small tax case procedure since the amount of deficiency placed in dispute (including additions to tax) for each year does not exceed $ 10,000. Held, further, Ps' motion to reinstate small tax case designation is granted; Ps' motion to make an amendment to…
1Opinion of the Court
OPINION
STERRETT, Chief Judge:
This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7456 of the Code.1 The Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.
OPINION OP THE SPECIAL TRIAL JUDGE
PANUTHOS, Special Trial Judge:
This case is before the Court on three related motions by petitioners: (1) Motion to reinstate small tax case designation; (2) motion to make an amendment to petition; and (3) motion to change designation of place of trial. The issue for consideration is whether petitioners can obtain small tax…
2Cases cited3 opinions
- Page v. CommissionerUnited States Tax Court · 1986
- Earl v. CommissionerUnited States Tax Court · 1982
- Dressler v. CommissionerUnited States Tax Court · 1971
3Cited by13 opinions
- Powerstein v. CommissionerUnited States Tax Court · 1992
- Schwartz v. Comm'rUnited States Tax Court · 2007
- Petrane v. Comm'rUnited States Tax Court · 2007
- APPEL v. COMMISSIONERUnited States Tax Court · 2004
- Gilda A. Petrane v. CommissionerUnited States Tax Court · 2007
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